The threshold for systemic payment processors raised to 400 million

A royal decree of October 11, 2026, increases the threshold above which a payment operations processor is considered to be of systemic importance in Belgium from 125 to 400 million operations per year and per payment scheme. The text, signed by King Philippe and countersigned by the Minister of Finance Jan Jambon, is published in the Belgian Official Gazette (Moniteur belge) No. 240 of October 21, 2026, page 56732, under reference C − 2026/007662.

The decree amends Article 5, paragraph 1, of the law of March 24, 2017, relating to the supervision of payment operations processors: the words “one hundred and twenty-five million” are replaced by the words “four hundred million.” The purpose of this law is to regulate processors whose activity is of systemic importance, in order to guarantee the continuity of payment services.

At the time the law was adopted, the threshold of 125 million operations corresponded to approximately 10% of the total volume of card payment operations carried out in Belgium. Since 2015, this total volume has more than doubled to reach approximately 3.1 billion operations in 2025, with an average annual growth of about 7%: consequently, the threshold represented only about 4% of the total volume.

A threshold that became too low

The government notes that the current threshold, being “too low,” no longer allows for the effective limitation of the law’s scope to only those processors that are truly systemic. The adjustment aims to take into account not only the current volume of payment operations but also their anticipated growth in the coming years.

The stated objective is twofold: to preserve the qualification of systemic importance for truly critical actors and to ensure the proportionality of the supervisory framework.

The procedure and opinions gathered

The file was processed by the Federal Public Service Finance and gathered the following opinions:

• Favorable opinion from the National Bank of Belgium, issued on June 23, 2026.
• Favorable opinion from the Finance Inspector, issued on August 27, 2026.
• Agreement from the Minister of Budget, given on September 7, 2026.
• Opinion 80.034/2 from the Council of State, given on September 30, 2026, in application of Article 84, § 1, paragraph 1, 2°, of the coordinated laws on the Council of State.

What the measure changes in practice

The text contains only two articles. Article 1 proceeds with the substitution of words in the law of March 24, 2017; Article 2 charges the minister responsible for Finance with the execution of the decree. The published text does not provide for any specific entry-into-force provision.

The consequence is direct for providers: a processor that exceeds 125 million annual operations per payment scheme without reaching 400 million no longer meets the legal criterion and should therefore no longer be qualified as systemically important. As the threshold remains assessed per payment scheme, and not on the operator’s overall activity, the scope will depend on the distribution of volumes between schemes.

For industry readers, the issue is one of cost and the intensity of prudential supervision: the law of March 24, 2017 subjects systemic processors to a specific control regime, the scope of which is mechanically tightened by the decree. Actors who crossed the old threshold without reaching the new one benefit from regulatory relief, while the National Bank of Belgium retains control over the assessment of individual situations as part of its supervisory mission.

Source: Belgian Official Gazette (Moniteur belge) No. 240 of October 21, 2026, p. 56732, royal decree of October 11, 2026 amending the law of March 24, 2017 relating to the supervision of payment operation processors, reference C − 2026/007662.